N.Y. Abandoned Property Law (APL) Art. XIII · NY Office of the State Comptroller — Office of Unclaimed Funds (OUF)

New York March 10 Corporate Deadline, OUF Voluntary Compliance & Full-Value Gift Cards

New York's Office of Unclaimed Funds enforces a strict March 10 spring reporting deadline for general corporations, dual-tier first-class and certified due-diligence mailings, and full-face-value gift card escheatment.

Deadline: March 10 Cutoff: December 31 No Statutory B2B Exemption Zero Report: Conditional

New York Statutory Dormancy & Compliance Schedule

NAUPA Property Stream	Statutory Dormancy	Compliance Rule
Uncashed AP Vendor Checks (CK13)	3 yrs	New York does not recognize a B2B exemption; commercial vendor checks, customer credit balances, and corporate rebates with NY-addressed owners must be reported after 3 years.
Payroll, Wages & Commissions (MS01)	3 yrs	Never B2B exempt; applies to employee final & bonus checks.
AR Credit Balances & Overpayments (MS09)	3 yrs	Write-offs to income do not extinguish reporting obligation.
Customer Refunds (MS05)	3 yrs	Due diligence window: 90 days prior to March 10 (by Dec 10); Certified mail >= $1,000.
Gift Cards & Stored Value (GC / MS12)	5 yrs (100% full face value)	Unaddressed cards route to corporate domicile under 2nd Priority.
Securities & Dividends (SC01 / SC08)	3 yrs	Mandatory Certified Mail (Return Receipt) >= $1,000 at least 60 days prior
Virtual Currency / Digital Assets (VC)	3 yrs (native/custodial)	Verify liquidation vs. native custodial transfer mandate.

Key New York Compliance Traps & Enforcement Risks

Certified Mail Mandatory >= $1,000 For any single property valued at $1,000 or more, New York APL requires certified mail with return receipt requested at least 60 days prior to March 10, in addition to 90-day first-class mailings.

Full Face Value Gift Card Escheatment Unlike states that exempt gift cards or allow retailer cost-of-goods deductions, New York requires 100% of unused gift card balances after 5 years.

OUF Self-Audit Outreach Letters New York proactively sends compliance inquiry notices inviting holders into a 6-month OUF Self-Audit; ignoring these inquiries escalates directly into formal OUF audit assignment.

NY OUF Voluntary Compliance Program (VCP / Self-Audit)

6-month self-audit window covering 10-year + dormancy reach-back; 100% waiver of 10% statutory interest and daily late penalties for first-time or voluntary reporters.

Statutory Interest & Penalties: 10% per annum interest + $100/day late-filing penalty. Negative Report Policy: Required for certain regulated entities and entities contacted via OUF outreach; standard commercial corporations file when property exists or under VCP.

Statutory Questions & Answers

What is the dormancy period for unclaimed wages in New York?

Under N.Y. APL § 1315, unclaimed wages and payroll checks for general corporations carry a 3-year dormancy period—longer than the 1-year rule common in most states.

Does New York accept NAUPA II files directly online?

Yes, OUF mandates electronic filing and electronic remittance for general corporate reports due on or before March 10.